Sahney Steel and Press Works Ltd. v. CIT

228 ITR 253Supreme Court of India1997#166 most cited

What is Sahney Steel and Press Works Ltd. v. CIT authority for?

A subsidy is treated as a revenue receipt if the assessee is free to use the money in its business as it likes and is not obligated to spend it for a specific capital purpose, such as acquiring assets or repaying loans.

429

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

Sahney Steel and Press Works Ltd. v. CIT · subsidy revenue receipt · capital receipt · taxability of subsidies · Section 2(24)(xviii) · Section 37(1) · purpose of subsidy · obligation to spend · income tax treatment of subsidies

Sections most often in play

Section 143(3)Section 115JBSection 14ASection 2(24)(xviii)Section 37(1)Section 32Section 43(1)Section 147

Issues it is cited on

section 2(24)(xviii)section 43(1)section 40(a)(ii)book profitsdeduction under section 80iablock of assetssection 80hhcadditional depreciationwritten down valuesection 139(5)section 80hhsection 2(24)

Judgments citing Sahney Steel and Press Works Ltd. v. CIT

M/S Vardhman Textiles Ltd vs. C I T and Anr

ITA/517/2008HC Punjab & Haryana26 Feb 2026

Bench: MR. JUSTICE AMARINDER SINGH GREWAL,MR. JUSTICE JAGMOHAN BANSAL

Section 10Section 143(1)Section 260ASection 80Section 80l

…IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH **** 204-1 ITA-517-2008 (O&M) Date of Decision: 26.02.2026 M/S VARDHMAN TEXTILES LTD. ...Appellant Versus COMMISSIONER OF INCOME TAX & ANR. ...Respondents And Sr. No. Case No. Appellant (s) Respondent(s) 2. ITA-292-2019 (O&M) The Pr. Commissioner of Income Tax M/s Vardhman Textiles Ltd 3. ITA-128-2021 (O&M) Chief Commissioner of Income Tax M/s Vardhman Textiles Ltd 4. ITA-428-2018 (O&M) The Pr. Commissioner of Income Tax M/s Vardhman Textiles Ltd 5. ITA-323-2019 (O&M) Pr. Commissioner…

The India Cements Limited, Chennai vs. DCIT Corporate Circle 2(1) Chennai, Chennai

In the result, appeal filed by the assessee is partly allowed

ITA 2174/CHNY/2024[2017-18]Status: DisposedITAT Chennai02 Jan 2026AY 2017-18
Section 10(39)Section 115JSection 14A

…e has been deducted from income for income tax purposes. 9.3. The assessee's submissions are considered but not found to be acceptable. The issue is a settled one in view of the decision of Hon'ble Supreme Court in the case of Sahney Steel & Press Works Ltd - 228 ITR 253, wherein, the Apex Court held that payments from public funds to assist companies in carrying on trade or business revenue receipts. Accordingly, refund of power subsidies are operational subsidies and to be treated as revenue receipts. The above decision of Hon'ble Supreme Court is squarely applicable to the facts of the case. 9.4. Further, on t…

JCIT Cent. Cir. - 1(4), Mumbai vs. Grasim Industries Ltd, Mumbai

The appeal is allowed

ITA 1561/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar / Ms SukanyaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 153CSection 250Section 43BSection 80I

…further period of time, the Ld. AO cannot dispute the same. In any case, the assessee submits that it has been settled by various judicial pronouncements, including the decision of the Hon’ble Supreme Court in Sahney Steel and Press Works Ltd. and Ors. V CIT (228 ITR 253) (SC), CIT Vs. Ponni Sugars & Chemicals Ltd. (306 ITR 392) (SC), the form of mechanism through which subsidy is given is irrelevant; the crucial determining factor is the purpose for which the subsidy is given. The purpose of the subsidy under which the assessee has been granted an incentive is accepted to be for rapid industrialisation and to en…

Grasim Industries Ltd, Mumbai vs. DCIT Cent. Cir. - 1(4), Mumbai

The appeal is allowed

ITA 1056/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

Section 153CSection 250Section 43BSection 80I

…further period of time, the Ld. AO cannot dispute the same. In any case, the assessee submits that it has been settled by various judicial pronouncements, including the decision of the Hon'ble Supreme Court in Sahney Steel and Press Works Ltd. and Ors. V CIT (228 ITR 253) (SC), CIT Vs. Ponni Sugars & Chemicals Ltd. (306 ITR 392) (SC), the form of mechanism through which subsidy is given is irrelevant; the crucial determining factor is the purpose for which the subsidy is given. The purpose of the subsidy under which the assessee has been granted an incentive is accepted to be for rapid industrialisation and to en…

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5417/DEL/2017[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…R SETTING UP OF THE INDUSTRIES. 4.3) The subsidies received by the assesee are within the purview of the principles laid down to treat the subsidy as revenue receipts by the HON'BLE APEX COURT IN THE CASE OF SAHNEY STEEL AND PRESS WORKS LTD. AND OTHERS VS.CIT(228 ITR 253). As observed by the Apex Court the assessee was free to use the money in its business entirely as it liked and WAS NOT OBLIGED TO SPEND THE MONEY FOR A PARTICULAR PURPOSE like expansion of the unit/purchase of machinery/purchase of capital goods/purchase of raw materials /repayment of loans like in the case of Ponni Sugars & Chemicals Ltd. In vi…

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5416/DEL/2017[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…R SETTING UP OF THE INDUSTRIES. 4.3) The subsidies received by the assesee are within the purview of the principles laid down to treat the subsidy as revenue receipts by the HON'BLE APEX COURT IN THE CASE OF SAHNEY STEEL AND PRESS WORKS LTD. AND OTHERS VS.CIT(228 ITR 253). As observed by the Apex Court the assessee was free to use the money in its business entirely as it liked and WAS NOT OBLIGED TO SPEND THE MONEY FOR A PARTICULAR PURPOSE like expansion of the unit/purchase of machinery/purchase of capital goods/purchase of raw materials /repayment of loans like in the case of Ponni Sugars & Chemicals Ltd. In vi…

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3158/CHNY/2017[2014-15]Status: DisposedITAT Chennai31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…R SETTING UP OF THE INDUSTRIES. 4.3) The subsidies received by the assesee are within the purview of the principles laid down to treat the subsidy as revenue receipts by the HON'BLE APEX COURT IN THE CASE OF SAHNEY STEEL AND PRESS WORKS LTD. AND OTHERS VS.CIT(228 ITR 253). As observed by the Apex Court the assessee was free to use the money in its business entirely as it liked and WAS NOT OBLIGED TO SPEND THE MONEY FOR A PARTICULAR PURPOSE like expansion of the unit/purchase of machinery/purchase of capital goods/purchase of raw materials /repayment of loans like in the case of Ponni Sugars & Chemicals Ltd. In vi…

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3157/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…R SETTING UP OF THE INDUSTRIES. 4.3) The subsidies received by the assesee are within the purview of the principles laid down to treat the subsidy as revenue receipts by the HON'BLE APEX COURT IN THE CASE OF SAHNEY STEEL AND PRESS WORKS LTD. AND OTHERS VS.CIT(228 ITR 253). As observed by the Apex Court the assessee was free to use the money in its business entirely as it liked and WAS NOT OBLIGED TO SPEND THE MONEY FOR A PARTICULAR PURPOSE like expansion of the unit/purchase of machinery/purchase of capital goods/purchase of raw materials /repayment of loans like in the case of Ponni Sugars & Chemicals Ltd. In vi…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. ITO Ward6(1), Pune

In the result, ITA Nos.154 to 156/PUN/2025 filed by the

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, 1d. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon'ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. National Faceless Appeal Centre, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, ld. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. ITO Ward 6(1), Pune

In the result, ITA Nos.154 to 156/PUN/2025 filed by the

ITA 155/PUN/2025[2017-198]Status: DisposedITAT Pune22 Dec 2025AY 2017-198

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025

Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, 1d. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon'ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. National Faceless Appeal Centre, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, ld. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

Shriniwas Engineering Auto Components Pvt. Ltd., Pune vs. ACIT, Circle-5, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, ld. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

Dy. Commissioner of Income-Tax, Circle-5, Pune vs. Shriniwas Engineering Auto Components Pvt. Ltd., Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, ld. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

ACIT, Circle-5, Pune vs. Shriniwas Engineering Auto Components Private Limited, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…eration, ld. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

ACIT, Pune vs. Shriniwas Engineering Auto Components Private Limited, Pune

In the result, ITA Nos.154 to 156/PUN/2025 filed by the

ITA 1843/PUN/2024[2018]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025

Section 2(24)(xviii)Section 43

…eration, 1d. CIT(A) has affirmed the action of the AO. After discussing the incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon'ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets pr…

Balaji Powertronics, New Delhi vs. DCIT, Circle- 43(1), New Delhi

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2743/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2017-18 M/S. Balaji Powertronics, Vs. Dcit, Circle-43(1), H-56, Udyog Nagar, New Delhi Main Rohtak Road, Delhi – 1100 41 Pan :Aagfb0501M (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 270ASection 80Section 928A

…y was given should not be decisive factor determining whether the subsidy was revenue or capital in nature. The principle for deciding the nature of subsidy had also been spelt out by the Hon'ble Apex Court in the case of Sahney Steel and Press Works Vs. CII (228 ITR 253) wherein it had been held that the character of the subsidy in the hands of recipient whether revenue or capital would have to be determined by having regard to the purpose for which the subsidy was given. 2.4 Reference in this regard is also invited to the decision in the case of Shree Balaji Alloys & Ors. Vs. CIT & Ors. (51 DTR 217) wherein the…

Deputy Commissioner of Income Tax, Central Circle 3(3), Mumbai vs. Welspun Living Limited, Mumbai

In the result, the appeal by the Revenue for the assessment year 2015-

ITA 3697/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Oct 2025AY 2015-16

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri Harsh KapadiaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115Section 14ASection 250

…appeal, the Revenue has raised the following grounds: - “1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in ignoring the Supreme Court decision in the case of Sahney Steel & Press Works Limited vs. CIT [1997) 228 ITR 253 (SC) wherein it is held that subsidy is provided to assist the assessee in carrying on his trader business and it is revenue receipt. The sales tax incentives are based on purchase and sale of goods. The incentives are not in the nature of a lump sum amount paid by the Government. 2. Whether on the facts and in the circumstances of the case and i…

Deputy Commissioner of Income Tax, Central Circle 3(3), Mumbai vs. Welspun Living Limited, Mumbai

In the result, the appeal by the Revenue for the assessment year 2015-

ITA 3696/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Oct 2025AY 2013-14

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri Harsh KapadiaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115Section 14ASection 250

…appeal, the Revenue has raised the following grounds: - “1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in ignoring the Supreme Court decision in the case of Sahney Steel & Press Works Limited vs. CIT [1997) 228 ITR 253 (SC) wherein it is held that subsidy is provided to assist the assessee in carrying on his trader business and it is revenue receipt. The sales tax incentives are based on purchase and sale of goods. The incentives are not in the nature of a lump sum amount paid by the Government. 2. Whether on the facts and in the circumstances of the case and i…

Maharashtra State Road Development Corporation Ltd, Mumbai vs. DCIT 5(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3484/MUM/2014[2006-07]Status: DisposedITAT Mumbai27 Oct 2025AY 2006-07

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Dalpat Shah, Shri. B S SharmaFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 143(3)Section 147Section 250

…velopment. As a result such a grant is a revenue in nature and ought to have offered for tax by the assessee following the law laid down by the Hon, Apex Court through the judgements in the following cases, 1. Sahney Steel & Press Works Ltd. etc. etc. vs. CIT 228 ITR 253 (SC) 2. CIT vs. Rajaram Maize Products 251 ITR 427 (SC) 3. Bengal Textiles Association vs. CIT 39 ITR 723 (SC) 5 I.T.A. No. 3484/Mum/2014 Maharashtra State Road Development Corporation Considering the facts of the case, accounting principles and law pronounced by the Hon. Apex court through the judgements sited above a sum of Rs. 17809 lakhs is…